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Home My WebLink About08-6075. _ ., Our'File No.: 186473 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. AMY E HAUF A/K/A AMY BELL 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0$ - &015 C,IViI T°t.r'ri7 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 } Our'File No.: 186473 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. AMY E HAUF A/K/A AMY BELL 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 Sc - (.0 7s CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is DISCOVER BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are AMY E HAUF A/K/A AMY BELL, an adult individual residing at 6204 STANFORD CT MECHANICSBURG, PA 17050-5245. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002300254018. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $5,563.05. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,563.05 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & OFebt TES, P.C. Attorney or Pl ff A Law Firm Ens ed in Collectioi BY: David J. Ammer, Esquire Dated: 10/1/2008 Our File No.: 186473 k VERIFICATION David J. Apothaker, Esquire, Esc. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and therein are made subject to the penalties of 18 David J. A$( Attorney The undersigned understands that the statements relating to unworn falsification to authorities. ker, Esquire Plaintiff DATE: 10/1/2008 DISCOVER BANK AMY E HAUF A/K/A AMY BELL 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 STATEMENT OF ACCOUNT Debtor's Name: AMY E HAUF A/K/A AMY BELL Account Number: 6011002300254018 Balance Due: $5,563.05 Our File No.: 186473 EXHIBIT "A" " sue c 'F n_ ? cn A a ?' SHERIFF'S RETURN - REGULAR CASE NO: 2008-06075 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HAUF AMY E A/K/A AMY BELL NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HAUF AMY E A/K/A AMY BELL was served upon DEFENDANT , at 0018:20 HOURS, on the 14th day of October at 6204 STANFORD CT MECHANICSBURG, PA 17050 by handing to AMY BELL DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 12.00 .00 10.00 .00 40.00 Sworn and Subscibed to before me this the 2008 day So Answers: 1!0? t-IX-o - R. Thomas Kline 10/15/2008 APOTHAKER & ASSOCIATES By: ze??, Deputy Sheriff of A. D. A Our File No.: 186473 APOTHAKER &.ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 DISCOVER BANK VS. Plaintiff, AMY E HAUF A/K/A AMY BELL Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6075 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, AMY E HAUF A/K/A AMY BELL, in the default of an Answer, in the amount of $5,563.05 computed as follows: Amount claimed in complaint: $5,563.05 Amount Paid: - $(0.00) Interest from October 01, 2008 to 05/14/09 at the legal interest rate of 0.000 per annum $0.00 Costs $0.00 Attorney fees $0.00 TOTAL $5,563.05 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, AMY E HAUF A/K/A AMY BELL, last know address is 6204 STANFORD CT MECHANICSBURG, PA 17050-5245. APOTHAKER & Attorneys A Law Firm Emu By: David J. TES, P.C. Collection Dated: 5/14/2009 Our File No.: 186473 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff DISCOVER BANK Plaintiff, VS. AMY E HAUF A/K/A AMY BELL Defendant. Civil Action AFFIDAVIT OF NON-AHLITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6075 . SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 6204 STANFORD CT MECHANICSBURG, PA 17050-5245. We inquired with the web site of the Defe Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apo i er Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/ar. i any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DeperMaent ofDeftepse Manpower Data Center MAY 14-200910:49:43 Based on the itkanatim you have 1'weisrshed, the Upon searchiag dre i6omradon dwa basics of the Depfarmtmt of Definse Mae power Data Cam, bred on the =won that you provided, the above is the conva swus of the indrAnd to d branches dire wry. 44" Oltiv w of Mary M Saauelyr-Ann, D"ckr Dnmunentof Ikfiense Mmp mw Data Center 1600 WrlsonHW , Saito 400 Ate, VA 22209-2393 The Defaw Mantaawcr Data Center (?M€) is an e of the meat ofd fat rani sins the Defense F.trohnat and ElgW Repor" Systm (DEERS) use wfich is the oMcW source of&& cn elig ility;for awry wo&ui care and other ' Wly system. The Dqmemseet of Defense *oo*y sqpporls the t of the Savers Grad Refs f Act [30 USCS Ann- ff 501 et segj (SCRA) fonnedy dre Sags' and SAW Reif Act of 1940)_ DWDC has issued hua&eds of6munds of-does not possess my man indicating that the indiv;&W is cnnv* an alive cisty* responsm and has experienced a must error rte. In the event the indrvidud refam:ed above, or any fmrily use be r, MwdL or representative asserts in any amwer that the iadkrided is an alive duty, car is clnvalse entitled to dre protedions of the SCRA, you are *co* encouraged to obtain fader ved&m On ofthe person's active duty by contacting dart pen's MEtKy Samice via the "de6m mT URL provided below. If you have evidence the person is an awe-d ty and you fait to obtaindhis arMdiional Mltwy Service via, pr rions of the SCRA may be invoked agwast you. K you obt a in about the person ( e.g. an SSN. improved accuracy of DOB, a m lac naaee), you can shit your regaest spin at d is Web site and we will provide anew date for that query. Toms response re$ects current active duty stns n only For historical zfennabon, please cooed the Mtary Service SCRA powas- cd'-coutact. Seems bttVd/WWW. 49SLDR httnl WAP14M This certificate was provided based on ar name and Soci d Security umber (SSN) provided by the mpester- Prtrvitling an enroneans ame or SSN wil cause an cameous cerdle de to be provided. 40 Miry Stag Report Pum aa to fire See<victmea hers City ReldAct 186473 DISCOVER BANK VS. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY AMY E HAUF A/K/A AMY BELL To: AMY E HAUF A/K/A AMY BELL 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6075 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 14, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA%rib . APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06075 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HAUF AMY E A/K/A AMY BELL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAUF AMY E A/K/A AMY BELL the DEFENDANT at 0018:20 HOURS, on the 14th day of October , 2008 at 6204 STANFORD CT MECHANICSBURG, PA 17050 by handing to AMY BELL DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the 3' thereof Sheriff's Costs: So Answers: Docketing 18.00 Service 12.00 Affidavit .00 "1* Surcharge 10.00 R. Thomas Kline .00 40.00 10/15/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheriff of , A.D. T' i Alli THE 2 AY 20 Ai I Ij: 4 8 4 . ?A 14-oo Pp AT'N w IM 143 e* aa.53`? 1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: AMY E HAUF A/K/A AMY BELL 6204 STANFORD CT MECHANICSBURG, PA 17050-5245 DISCOVER BANK Plaintiff, vs. AMY E HAUF A/K/A AMY BELL Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } NO.: 08-6075 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 5/,20/07 • 4 Our File No.: 186473 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff DISCOVER BANK Plaintiff, vs. AMY E HAUF A/K/A AMY BELL Defendant. ;^ ~F, ~~ ~~ r . ~. ~~ .. TAR}, 2(~1?,,~~ PH 4.2~ rU ; ~Yt ~~ ~,. ~~` COURT OF COMMON PLEAS CUMBERLAND COUNTY ~ '', +~ r ~ ~ NO. 08-6075 ~~ ° ~~ '°' ~, , ~ -~ Z a ~ 7~Z t? r7 r~ --+ ~ PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER & S OCIATES, P.C. Attorney for laintiff A Law Firm Ensa ed ' Debt Collection By: David J. A * 4- 1 8 6 4 7 3- S A T- 1-~ Esquire ~R.So P~ ,~r C~ t 00000 8' ~'~o~Qs